Dave,
Our house is all concrete, including the roof system. The roof, as all floors, are made of steel bar joist with 4" of concrete on top. The roof has foam insulation on top of the slab, osb decking and then roof rubber. It's a flat roof. Under the slab is mostly filled with insulation. the pex tube is laying on the top side of the dry wall, so under all the insulation.
If by chance it did freeze, Pex is freeze friendly. wouldn't do you much good in a fire though. So far, one year in use and no leaks.
Patrick t